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This article examines the substance-based income exclusion under Pillar Two, highlighting its shortcomings and suggesting alternatives.
This article critically examines the substance-based income exclusion (SBIE) under Pillar Two, highlighting its conceptual shortcomings, allocative distortions and bias toward tangible-intensive business models. It argues that the current formula inadequately reflects economic reality and proposes alternative approaches for determining routine returns consistent with modern multinational activities.
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Ramon Tomazela (2026) studied this question.
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